{"operation":"document","citation":"CPF 420161010H","title":"NORTHERN NATURAL GAS CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-09-01","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161010h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161010h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161010h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420161010H","body":"Corrective Action Order involving NORTHERN NATURAL GAS CO. The dataset does not identify a cited regulation for this case. The case was opened on 2016-09-01 and is reported as closed as of 2022-12-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420161010H_Closure Letter_12272022_(16-154270S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161010H/420161010H_Closure%20Letter_12272022_(16-154270S).pdf\n\n420161010H_Closure Letter_12272022_(16-154270S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161010H/420161010H_Closure%20Letter_12272022_(16-154270S)_text.pdf\n\n420161010H_Corrective Action Order_09012016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161010H/420161010H_Corrective%20Action%20Order_09012016.pdf\n\n420161010H_Corrective Action Order_09012016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161010H/420161010H_Corrective%20Action%20Order_09012016_text.pdf\n\n420161010H_Closure Letter_12272022_(16-154270S)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Thomas.Correll@nngco.com; mark.hewett@nngco.com;\nGary.Krichau@nngco.com; Shannon.McGuire@nngco.com\nDecember 27, 2022\nMr. Tom Correll\nVice President, Pipeline Safety and Risk\nNorthern Natural Gas\n1111 South 103rd Street\nOmaha, NE 68124\nRe: CPF 4-2016-1010H\nDear Mr. Correll,\nOn September 1, 2016, The Pipeline and Hazardous Materials Administration (PHMSA) issued\nto Northern Natural Gas Company (NNG) a Corrective Action Order in the above referenced\ncase. This Order required that NNG take certain corrective actions with respect to its 640A\nnatural gas mainline that failed on August 25, 2016. Based on our review of documentation\nprovided, it has been determined that NNG has complied with the terms of the Corrective Action\nOrder.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Mark Hewett, President/CEO, Northern Natural Gas, mark.hewett@nngco.com\nGary Krichau, Northern Natural Gas, Gary.Krichau@nngco.com\nShannon McGuire, Northern Natural Gas, Shannon.McGuire@nngco.com\n\n420161010H_Corrective Action Order_09012016_text.pdf\n\nSeptember 1, 2016\nMr. Mark A. Hewitt\nPresident and CEO\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 69124\nRe: CPF No. 4-2016-1010H\nDear Mr. Hewitt:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Northern\nNatural Gas Company to take certain corrective actions with respect to your 640A natural gas\nmainline that failed on August 25, 2016, near Ellsworth, Kansas. Service is being made by\ncertified mail and facsimile. Service of the Corrective Action Order by electronic transmission is\ndeemed complete upon transmission and acknowledgement of receipt, or as otherwise provided\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion\nof service.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Acting Deputy Associate Administrator for Field Operations, OPS\nMr. Rodrick Seeley, Regional Director, Southwest Region, OPS\nVIA CERTIFIED MAIL AND FAX\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n_______________________________________________\nIn the Matter of )\nNorthern Natural Gas Company, ) CPF No. 4-2016-1010H\na subsidiary of Berkshire Hathaway Energy Company, )\n)\n)\n)\nRespondent. )\n_______________________________________________ )\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112,\nto require Northern Natural Gas Company (NNG or Respondent), to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on NNG’s 640A natural gas mainline.1\nOn August 25, 2016, an incident occurred on the company’s 640A natural gas mainline (640A\nPipeline), resulting in the release of an unknown amount of natural gas (Failure). The 640A\nPipeline is a 26-inch-diameter transmission pipeline approximately 606.9 miles in length that\ntransports natural gas from Bushton, Kansas, to Palmyra, Kansas, with an east leg that ends at\nOgden, Iowa, and a west leg that ends at Sioux City Nebraska.2 The cause of the Failure has not\nyet been determined. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of\nthe incident. The preliminary findings of the ongoing investigation are as follows.\nPreliminary Findings:\n The failed pipeline segment is a 26-inch-diameter line that transports natural gas from\nBushton, Kansas, to Tescott, Kansas, a distance of approximately 45.6 miles. The Failure\noccurred near Milepost 30 (MP 30 or Failure Site) near Ellsworth, Kansas.\n1 NNG, a subsidiary of Berkshire Hathaway Energy Company, owns and operates the largest interstate natural gas\npipeline system in the United States, crossing 11 states from the Permian Basin in Texas to Michigan's Upper\nPeninsula. See http://www northernnaturalgas.com/aboutus/Pages/Overview.aspx (last accessed August 29, 2016).\n2 While the incident occurred in Kansas (PHMSA Central Region), the Southwest Region is responsible for the\ninspection of this System.\n\n\n\nCPF No. 4-2016-1010H\nPage 2\n The incident occurred on the 640A line, which is a coupled, bare steel line. In this area, it\nis protected by rectifiers, since all the dresser couplings are bonded.\n The Failure occurred in a remote, rural location, with no injuries, fatalities, evacuations,\nor ignitions reported.\n NNG has five parallel pipelines in the area. The nearest parallel line is approximately 500\nfeet away and does not appear to be impacted. The adjacent lines are being examined to\nensure their continued serviceability and the site investigation of the failed line will\ncontinue once the confirmation of the parallel lines’ integrity is complete.\n At the Failure Site, two pieces of pipe were found; one was found roughly 10-20 yards\neast of the Failure Site and a larger piece (about 30 feet in length) was found roughly 100\nyards east of the Failure Site.\n The 640A Pipeline was constructed in the 1930’s. The Affected Segment is a 26-inch\nbare steel, dresser-coupled line, constructed of Grades X40, X42 and X52. The integrity\nof the Affected Segment is unknown.\n The maximum allowable operating pressure (MAOP) of the 640A Pipeline is 520 psig.\nMAOP was established using a hydrostatic test that was performed in 1963. At the time\nof the Failure, the actual operating pressure of the pipeline was 476 psig.\n At approximately 1:40 pm CST on August 25, 2016, NNG received notification from the\nlocal sheriff’s office regarding the release of natural gas from its pipeline.\n At approximately the same time as the notification from the sheriff’s office, NNG noticed\nan indication on its SCADA system and began taking steps to isolate the failed section of\npipeline in the area. NNG closed Valve 640ABA04 at MP 26.73 and Valve 640ABA07\nat MP 42.45.\n The cause of the Failure is currently unknown and the investigation is ongoing. The\npipeline remains shut-in from MP 26.73 (Valve 640ABA04) to MP 42.45 (Valve\n640ABA07).\n The Failure Site is approximately 150 yards north of I-70 and approximately 1100 feet\nfrom the nearest structure. Interstate 70 and several local roads were closed for a short\nperiod of time because of the Failure.\n PHMSA’s last Integrated Inspection Unit profile included information regarding three\nprevious incidents on the 640A Pipeline. Contributing factors in those events included\ncorrosion, incorrect operation, stripped threads, and a broken pipe coupling. In addition,\na review of previous failures identified a 2004 failure just south of Clifton, Kansas,\n\n\n\nCPF No. 4-2016-1010H\nPage 3\ninvolving a girth weld failure (Accident report #20040123) on a 26-inch diameter, 0.280\ninch wall thickness, grade X52 pipeline manufactured by AO Smith.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the uncertainties as to the cause of the Failure; the\nproximity of the pipeline to populated areas and public highways; the age of the 640A Pipeline;\nthe difficulty in obtaining recent/accurate pressure-testing information for these older coupled\npipelines; and the history of problems or failures on the 640A Pipeline, I find that a failure to\nissue this Order expeditiously to require immediate corrective action would result in the\nlikelihood of serious harm to life, property, or the environment.\nAccordingly, this Order mandating immediate corrective action is issued without prior notice and\nopportunity for a hearing. The terms and conditions of this Order are effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin Southwest Region office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA\nmay identify other corrective measures that need to be taken. In that event, PHMSA will\nnotify Respondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nThe “Affected Segment” means approximately 606.9 miles of NNG’s 26-inch Line 640A from\nBushton, Kansas to Palmyra, Kansas where it splits into two segments, the west leg that travels\n\n\n\nCPF No. 4-2016-1010H\nPage 4\nto Sioux City, Nebraska and the other east leg travels to Ogden, Iowa. The “Affected Segment”\ngenerally runs northerly and passes through portions of Kansas, Nebraska and Iowa. According\nto NNG, approximately 95% of the line is coupled.\nThe \"Isolated Segment\" means the 15.6-mile segment of NNG’s 26-inch Line 640A between MP\n26.73 (640ABA04) and MP 42.45 (640ABA07). It is the portion of the \"Affected Segment\" that\nwas shut-in after the Failure on August 25, 2016, by closing main line valves MLV 640ABA04\n(upstream of the Failure Site) and MLV 640ABA07 (downstream of the Failure Site).\nThe \"Director\" means the Director, Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Southwest Region. The Director’s address is 8701 S.\nGessner, Suite 630, Houston, Texas 77074.\nPursuant to 49 U.S.C. § 60112, I hereby order NNG to immediately take the following corrective\nactions for the Affected Segment and Isolated Segment, if applicable:\n1. Operating and Pressure Restrictions. The Isolated Segment is to remain shut-in from\nregular operation.3 NNG may request approval from the Director to re-start the pipeline,\npursuant to Item 2. Pressure within the Affected Segment is not to exceed 80% of the actual\noperating pressure of 476 psig of the Affected Segment just prior to failure. The 80% pressure\nreduction will result in an operating pressure of 380 psig. This pressure restriction shall remain in\nplace until written approval, pursuant to Item 7, is obtained from the Director.\n2. Restart Plan. Prior to resuming operation of the Isolated Segment, NNG must develop\nand submit a written Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan but the Isolated Segment cannot resume operation until the Restart Plan is approved\nin its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. d. e. f. The Restart Plan must provide for adequate patrolling of the Isolated Segment during the\nrestart process and must include incremental pressure increases during start up, with each\nincrement to be held for at least two hours.\nThe Restart Plan must include sufficient surveillance of the pipeline during each pressure\nincrement to ensure that no leaks are present when operation of the line resumes.\nThe Restart Plan must specify a day-light restart and include advance communications\nwith local emergency response officials.\nThe Restart Plan must provide for a review of the Affected Segment for conditions similar\nto those of the Failure, including a review of construction, operating and maintenance\n(O&M) and integrity management records such as in-line inspection (ILI) results,\n3 At the time of this Order, NNG reports that the Isolated Segment is shut-in and not in service. In the event that\nNNG returns the Isolated Segment to service before receipt of this Order, NNG must immediately shut-in the\nIsolated Segment and seek approval from the Director before re-starting.\n\n\n\ng. CPF No. 4-2016-1010H\nPage 5\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground patrols,\ncorrosion, cathodic protection, excavations and pipe replacements. Operator must\naddress any findings that require remedial measures to be implemented prior to restart.\nThe Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications are\nincorporated into NNG’s operations and maintenance procedures manual.\n3. Return to Service. After the Director approves the Restart Plan, NNG may return the\nIsolated Segment to service but the operating pressure must not exceed eighty percent (80%) of\nthe actual operating pressure in effect immediately prior to the Failure (380 psig).\n4. Metallurgical Analysis. NNG must conduct a detailed metallurgical analysis of the\npipe that failed, to determine the cause and contributing factors for the Failure as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the Failure Site;\nb. Within 10 days of receipt of this Order, submit to the Director a proposed selection of the\ntesting laboratory and proposed metallurgical testing protocol for prior approval.\nc. Prior to commencing the mechanical and metallurgical testing, provide the Director with\nthe scheduled date, time, and location of the testing to allow a PHMSA representative to\nwitness the testing; and\nd. Ensure that the testing laboratory distributes all resulting reports in their entirety\n(including all media), whether draft or final, are provided to the Director at the same time\nas they are made available to NNG.\n5. Root Cause Failure Analysis. Within 90 days following receipt of this Order,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this RCFA to the\nDirector. The final report must include findings and any lessons learned and whether the\nfindings and any lessons learned are applicable to other locations within NNG’s pipeline\nsystem.\n6. Remedial Work Plan. Within 90 days following receipt of this Order, NNG must\nsubmit a Remedial Work Plan (RWP) to the Director for approval. The Director may approve\nthe RWP incrementally without approving the entire RWP. Once approved by the Director, the\nRWP will be incorporated by reference into this Order.\na. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures NNG will use to verify the integrity of the Affected Segment. It must address\nall known or suspected factors and causes of the Failure. NNG should consider both the\nrisk of another failure and the consequence of another failure to develop a prioritized\nschedule for RWP-related work along the Affected Segment.\nb. The RWP must include a procedure or process to:\ni. Identify pipe in the Affected Segment with characteristics similar to the contributing\n\n\n\nCPF No. 4-2016-1010H\nPage 6\nii. iii. iv. v. vi. vii. viii. c. factors identified in the Failure.\nGather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Segment and to prepare a written report containing all the\navailable information, such as the locations, dates, and causes of leaks and failures.\nIntegrate the results of the metallurgical testing, root cause failure analysis, and other\ncorrective actions required by this Order with all relevant pre-existing operational and\nassessment data for the Affected Segment. Pre-existing operational data includes, but\nis not limited to, construction, operations, maintenance, testing, repairs, prior\nmetallurgical analyses, and any third party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure\ntesting, direct assessments, close interval surveys, and DCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Failure are likely to exist\nelsewhere within the NNG pipeline systems.\nDescribe the inspection and repair criteria NNG will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity threats.\nInclude a description of how any defects will be graded and a schedule for repairs or\nreplacement.\nBased on the known history and condition of the Affected Segment, describe the\nmethods NNG will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the Failure and to address other known\nintegrity threats along the Affected Segment.\nImplement continuing long-term periodic testing and integrity verification measures\nto ensure the ongoing safe operation of the Affected Segment, considering the results\nof the analyses, inspections, evaluations, and corrective measures undertaken\npursuant to this Order.\nConduct additional field tests, inspections, assessments, and/or evaluations to\ndetermine whether, and to what extent, the conditions associated with the Failure and\nother failures from the failure history or any other integrity threats are present\nelsewhere on the Affected Segment. At a minimum, this process must consider all\nfailure causes and specify the use of one or more of the following:\n1. ILI tools that are technically appropriate for assessing the pipeline system based\non the cause of Failure on August 25, 2015 and that can reliably detect and\nidentify anomalies;\n2. Hydrostatic pressure-testing;\n3. Close-interval surveys;\n4. Cathodic protection surveys, to include interference surveys in coordination with\nother utilities (e.g. underground utilities, overhead power lines, etc.) in the area;\nand\n5. Other tests, inspections, assessments, and evaluations appropriate for the failure\ncauses.\nInclude a proposed schedule for completion of the RWP.\n\n\n\nCPF No. 4-2016-1010H\nPage 7\nd. i. ii. iii. e. NNG must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and/or to incorporate modifications required\nby the Director.\nSubmit any plan revisions to the Director for prior approval.\nThe Director may approve plan revisions incrementally.\nAny and all revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented in the CAO\nDocumentation Report (CDR).\nImplement the RWP as it is approved by the Director, including any revisions to the\nplan.\n7. Removal of Operating and/or Pressure Restriction. NNG may request approval from\nthe Director to remove or modify the operating and/or pressure restriction of the Isolated and\nAffected Segments, based on demonstrating that the hazard has been abated or that a higher\npressure is justified, and based on an analysis showing that the pressure increase is safe,\nconsidering all known defects, anomalies and operating parameters of the Isolated and\nAffected Segments. The request should include a return to service plan with the final results\nof all testing and activities conducted pursuant to Items 2 and 3 above. The Director’s\ndetermination will be based on satisfactory completion of these requirements and evidence\nthat mitigative actions taken by the operator provide for the safe operation of the Isolated and\nAffected Segments.\n8. Reporting. NNG must submit quarterly reports to the Director that: (1) include all\navailable data and results of the testing and evaluations conducted pursuant to this Order; and\n(2) describe the progress of the repairs or other remedial actions being undertaken. The first\nquarterly report is due on December 1, 2016. The Director may change the interval for the\nsubmission of these reports.\n9. Documentation of Costs. It is requested, but not required, that NNG maintain\ndocumentation of the costs associated with implementation of this Corrective Action Order.\nInclude in each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies and analyses; (2) physical changes to pipeline\nfacilities, including repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\n10. Approvals. With respect to each submission that under this Order requires the\napproval of the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that NNG modify\nthe submission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, NNG shall proceed to take all action required by\n\n\n\nCPF No. 4-2016-1010H\nPage 8\nthe submission as approved or modified by the Director. If the Director disapproves all or\nany portion of the submission, NNG must correct all deficiencies within the time specified by\nthe Director, and resubmit it for approval.\n11. Extensions of Time. The Director may grant an extension of time for compliance\nwith any of the terms of this Order upon a written request timely submitted demonstrating\ngood cause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 192, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any\nother provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 4-2016-1010H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n______________________________ _____________________________________\nAlan K. Mayberry Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":25453}